TABLE 1: DISTRIBUTIONS FOR ISB1, ISB2, ISB3, CFA1
AND CFA2 BEFORE AND AFTER STATISTICAL TRANSFORMATIONS (N = 280) ISB1 ISB2 M/SD Raw data 5.
When CFA2 earns income from an active business, the income derived by CFA1 from the income transfer payment received from CFA2 is generally deemed to be from an active business under clause 95(2)(a)(ii)(B) of the Act.
Clause 95(2)(a)(ii)(B), however, would seemingly not apply to re-characterize the transfer payment received by CFA1 from CFA2 as income from an active business because the transfer of such income from CFA2 must be considered deductible under Canadian (rather than German) rules in computing CFA2's active income.
A fellow traveller who had fallen to such deception recounts: "I agreed to pay them CFA1
,000, then they took me to the border and collected all my money.
As discussed below, an interest-free loan from a taxable Canadian corporation to a controlled foreign affiliate (CFA1) to acquire shares in another CFA (CFA2) will produce the same tax results as though the funds were contributed to CFA1 as share capital.
CFA1 can acquire newly issued shares of CFA2 from CFA2;
CFA1 can purchase shares of CFA2 from another CFA (hereinafter the "disposing CFA") of CANCO; or
In other words, the same tax results would follow as though CANCO contributed share capital to CFA1 (as opposed to making an interest-free loan to CFA1).
When it became clear that the odds on Abidjan being reopened during the main cotton export season were virtually nil, a spokesperson for CMDT said: "Now, as the chances of this happening are dwindling and as we go to LomE in Togo, Tema in Ghana and Dakar in Senegal to export, the expected profit has been reduced to CFA1
On the eve of his European tour in February, the Prime Minister Pascal Affi N' Guessin expressed optimism that the donor community would provide the CFA1
,000bn he was seeking to redress the dire economic situation.
The biggest debtors include Cote d'lvoire, which owes Accor Afrique some CFA1
One of the reasons for it is the poor financial state of the public sector, which itself, alongside other factors, contributed towards creating a CFA1
,000bn public internal debt.